Payment Card Industry Data Security Program Standard
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Montana State University Effective Date: April 5, 2017 Review Date: April 5, 2020 Updated Date: Payment Card Industry (PCI) Data Security Program and Standard Brief Description: To ensure campus compliance with the Payment Card Industry Data Security Standard (PCI-DSS) Introduction: The purpose of this program is to ensure that payment card (credit card) and ecommerce activities are consistent, efficient, and secure to protect the interests of the University and its customers. This standard provides guidance to ensure that campus credit card acceptance and ecommerce processes comply with the Payment Card Industry Data Security Standard (PCI DSS) and are appropriately integrated with the University’s financial and other systems. Scope: This policy applies to Montana State University as well as its self-supporting operations, contractors, consultants, or agents who, in the course of doing business on behalf of the University, accept, process, transmit, store, or otherwise handle cardholder information in physical or electronic form. This policy also applies to all Montana State University organizations that accept process, transmit, store, or otherwise handle cardholder information in physical or electronic form. This policy applies to all types of credit card activity transacted in person, over the phone, via fax, mail, or the internet. System and device functionalities established for credit card data activities of the university may be used only for credit card data activities of the university, not for personal use. PCI Security Standards PCI security standards are technical and operational requirements set by the Payment Card Industry Security Standards Council to protect cardholder data. The standards globally govern all merchants and organizations that store, process, or transmit data, are mandatory for their respective stakeholders, and are enforced by the major payment card brands who established the Council: American Express, Discover Financial Services, JCB International, MasterCard Worldwide and VISA Inc. • PCI Data Security Standard: The PCI DSS applies to any entity that captures, stores, processes, or transmits cardholder data. It covers technical and operational system components included in or connected to cardholder data. Any business activity that accepts or processes payment cards must comply with the PCI DSS. • PCI Data Security Standard for Merchants and Processors: The PCI DSS is the global data security standard that any business of any size must adhere to in order to accept payment cards. It presents steps that appeal to common sense and mirror best security practices. Operating Principles The following operating principles must be used by departments when accepting credit card information in order to process payments for services, purchases, registration, etc. • All merchant sites and merchant card processors must be authorized and approved by University Business Services. This includes approval of the written agreement with the service provider. A written agreement must be made with each service provider. • Such authorization is required for new credit card acceptance channels / merchant accounts, and any addition or change to an existing channel/account including, but not limited to, the: o use of existing credit card acceptance channels / merchant accounts for new purposes o alteration of business processes that involve payment card processing activities o addition or alteration of payment systems or technologies o addition or alterations of relationships with third-party payment card service providers • All merchant card services offered by the University must be delivered using software, systems, and procedures that are compliant with applicable standards. • When processing credit card transactions, only the minimum amount of information necessary to verify the identity of the cardholder and the legitimacy of the cardholder authorization should be gathered. For example, manual requests to process a customer’s credit or debit card may contain the following elements: o Properly signed/executed authorization from the cardholder (unless processing over the telephone as provided for in NACHA guidance on TEL transactions) o Credit/debit card account number with expiration date o The cardholder’s correct billing address o Authorization codes (Card Identification Number), if the cardholder is not physically present Credit Card Merchant Numbers • All credit card merchant ID numbers must be obtained from University Business Services. Revenue-generating departments are prohibited from obtaining merchant ID numbers directly from the credit card companies or processors. • Departments must use only University Business Services approved third-party providers to ensure PCI compliance. Credit Card Acceptance Channels • Credit card information can be accepted through a Montana State University authorized web application, by telephone, or in person only. • Credit card information cannot be accepted via email (or similar messaging system), fax, voicemail and should never be emailed from the department. • If data must be written down, use the standard credit card authorization form found on the University Business Services website under PCI. Print this form out on bright paper, so that staff will know what it is by color. • Departments are not permitted to capture, transmit, process, or store credit card information on Montana State University computer systems, fax machines, the internet, email (or similar messaging system), or any removable electronic storage device (USB memory stick, hard drive, zip drive, etc.). • When possible, cashiering sites accepting credit card payments should only use Point of Sale terminals or equipment supplied to the location by the campus’ merchant card processor. In all cases, Point of Sale terminals and systems must be configured to prevent retention of the full magnetic strip, card validation code, PIN, or PIN Block cardholder data once a transaction has been authorized. o The three- or four-digit validation code printed on the payment card, referred to as the Card Identification Number (CID), must never be stored in any form. The CID number may also be referred to as the CVC2 or CVV2. o The full contents of any track data from the payment card’s magnetic stripe must never be stored in any form. o The personal identification number (PIN) or encrypted PIN block must never be stored in any form. o If electronic storage is authorized, the primary account number (PAN) must be rendered unreadable anywhere it is stored. o All but the last four digits of any credit card account number must be masked when it is necessary to display credit card data. Credit Card Information Storage • Paper records containing credit card data must be secured at all times, e.g., stored in a locked file cabinet or locked room in a secure storage container, if any, used for materials that are to be destroyed. Access to the storage area(s) must be limited to those who need access to the credit card data records. Credit Card Receipts • Credit card receipts that go to the customer and University Business Services may only show the last four digits of the credit card number. Also, the credit card expiration date should not appear on the receipt. Annual Self-Assessment and Periodic Internal Network Scan • Each department processing payment cards must complete an annual PCI DSS Compliance Internal Assessment Questionnaire. • Departments must work to resolve any exceptions listed in the questionnaire. Departments must also work with the PCI Working Team to resolve any compensating controls. Training • Employees who are expected to be given access to cardholder data shall initially be required to complete PCI DSS Training and then renew that training at least annually. • Employees shall be required to acknowledge at least annually that they have received training, understand cardholder security requirements, and agree to comply with these requirements. Definitions: Cardholder The customer to whom a payment card has been issued or the individual authorized to use the card. Cardholder Data At a minimum, cardholder data consists of the full PAN (primary account number). Cardholder data may also appear in the form of the full PAN plus any of the following: cardholder name, expiration date and/or service code. Encryption The process of converting information into an unintelligible form to anyone except holders of a specific cryptographic key (Use of encryption protects information that is between the encryption process and the decryption process from unauthorized disclosure.). Merchant or Merchant Department Any University department or other entity that accepts payment cards bearing the logos of any of the five members of the Payment Card Industry Security Standards Council (American Express, Discover, JCB, MasterCard or VISA) as payment for goods and/or services, or to accept donations. Payment Card Any payment card/device that bears the logo of American Express, Discover Financial Services, JCB International, MasterCard Worldwide, or VISA, Inc. Responsibilities: University Business Services University Business Services has been delegated the authority by the University to approve all physical payment locations, websites, third party processors, or any channel accepting credit card payments, and will be responsible for verifying that credit card payments are only accepted at approved locations using approved merchant card processors. Additional University Business Services responsibilities include: • Establishing and